The tax rules governing deferred compensation, codified at section 409A, are harsh and complex. The rules are focused on the least important policy considerations and overlook the most important. Professors Halperin and Yale suggest a different approach, one that would make the law simpler, fairer, and more effective.

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An executive with deferred comp terminates and changes resident state. When deferred comp is then distributed, which state (current "lived-in" or former "worked-in" taxes should be with held as liability?